ML19192A097
| ML19192A097 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/11/2019 |
| From: | Arizona Public Service Co |
| To: | Division of Operating Reactor Licensing |
| Lingam S, 301-415-1564 | |
| References | |
| Download: ML19192A097 (8) | |
Text
Palo Verde License Amendment Request for Emergency Plan July 11, 2019
- Change based on the following:
- NRC June 12, 2018 correspondence to NEI, Alternative Guidance for Licensee Emergency Response Organizations (ML18022A352)
- Technical Basis for Section II.B, Table B-1 of NUREG-0654, Revision 2 (ML16117A427)
- Exelon Midwest License Amendment Request (ML18053A159) and approved Safety Evaluation (ML19036A586) for changes to their Emergency Response Organization Palo Verde LAR 2
3 Critical Elements of License Amendment Request No change to current augmentation timeframes and process Augment at Alert for all facilities and ERO positions Use of an All Call and duty roster process for staffing 60 minutes during normal working hours and 120 minutes off hours Supplemented Rev. 2 NUREG 0654 on shift ERO to support maintaining 120 minute off hours augmentation Increase RP technicians to support onsite or offsite monitoring as needed RP Supervision/Dose Assessment on-shift Ensure that key ERO functions can be maintained for timeframe prior to augmented resources arrival Palo Verde LAR
4 Critical Elements of License Amendment Request (contd)
Remove on-shift Chemistry and Maintenance personnel Increase number of augmented ERO consistent with guidance in Rev. 2 Remove non-minimum staff positions from the emergency plan (maintain in procedures)
State of Arizona has reviewed and supports this amendment request State and federal agencies will be invited to a once every drill cycle minimum staff drill Palo Verde LAR
5 Additional resources to support the key ERO functions remain in place on-shift:
Additional Radiation Protection support for onsite and offsite field monitoring is available if needed The number of auxiliary operators on site (12, 4 per unit) allows for additional efforts to support operations and maintenance critical activities during the 120 minute augmentation time Dose Assessment and Radiation Protection leadership available on shift Offsite communications to State and Local government and the NRC Palo Verde LAR
6 Additional resources to support the key ERO functions remain in place on shift (contd):
Engineering Support in the form of the unaffected unit Shift Technical Advisor Security Leadership to support the callout process Augmented Command and Control assistance to the affected Unit Shift Manager in the form of two on-shift Shift Managers/Emergency Coordinators from the unaffected Units Shift Managers, Control Room Supervisors and Shift Technical Advisors are trained to the Emergency Coordinator position qualification Palo Verde LAR
Palo Verde LAR
- Schedule for LAR submittal 3rd Quarter 2019
- NRC review and Issuance of Safety Evaluation 1 year
- Scheduled Implementation Six Months following approval 7
Discussion/Questions